2016-11-23_GENERAL DOCUMENTS - C1981041

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because of flood damage that has occurred to this area. Included in Tab 9 of the SL -09 Bond Release application package was a revegetation evaluation report. This report was prepared by Cedar Creek Associates, Inc. (CCA). Snowcap Coal Company contracted CCA to evaluate the SL -09 Phase II and Phase III bond release areas. In addition, the Shadscale Reference Area was evaluated to provide cover values to facilitate comparison of success for the reclaimed units. Sampling of the SL -09 bond release block and the Shadscale Reference Area was conducted on June 1St through June 3, 2016. CCA used a systematic procedure to sample the bond release areas and the reference area. A grid was overlaid over both sample areas and thirty sample points were used in each area. Based on the observations made during the October 6, 2016 bond release inspection, the Division is proposing to withhold approval of Phase III bond release of Pond 11 (Area #4). Given this, SCC revised the revegetation monitoring report to exclude the sample data collected from the Pond 11 area to ensure the bond release areas still met the approved revegetation success criteria for vegetation cover. Given this, only 27 sample points of the original thirty were used to ascertain revegetation success. Using point -intercept methodology, both the bond release areas and the Shadscale Reference Area were sampled for vegetation cover using a laser point bar. At each sample point, a ten - meter transect was extended. At each one -meter interval along the transect, a laser point bar was situated parallel to, and approximately 4.5 to 5.0 feet vertically above, the ground surface. A set of 10 readings was taken specifically to record hits on vegetation (by species), litter (including standing dead), rock (>2mm), or bare soil. A total of 100 intercepts per transect were recorded. CCA demonstrated that the number of samples collected at the reclaimed area and reference area were adequate in accordance with Rule 4.15.11(2), even with the exclusion of sample points from the Pond 11 area. The sampling protocol used is in accordance with the sampling plan outlined in Tab 14 of the Roadside Mine permit and in accordance with Rule 4.15.11(1)(a)(i). The ground cover in the bond release areas (excluding Pond 11) consisted of 30.22% desirable perennial cover with annual and biennial cover averaging 23.78% absolute cover. Noxious weed cover was 7.96%. The dominant species observed were little barley (Criterion pusillum) and fourwing saltbush (Atriplex canescens) with 18.30% and 10.70% average cover, respectively. The ground cover in the Shadscale Reference area consisted of 18.27% desirable perennial cover, with annual and biennial cover averaging 1.7% absolute cover. Noxious weedcover was 39.97%. The dominant species were cheatgrass (Anisantha tectorum) and galleta (Hilaria jamesii), with 39.03% and 8.73% average cover, respectively. By direct comparison, the ground cover of desirable perennial vegetation of the bond release areas (30.22%) is greater than 90% of the ground cover of desirable perennial vegetation of the reference area (16.4%, which is 90% of 18.27%). As indicated above, the applicant demonstrated sample adequacy and in accordance with Rule 4.15.11(2)(a) met the revegetation success criteria for vegetation ground cover. The methodologies and calculations submitted with the CCA vegetation monitoring report were reviewed for adequacy and no problems were G 1981-041, SL -09 Findings Document Page 8 of 79